The Ampasindava peninsula is home to the last remaining forests of the Northern region and a coastal area particularly rich in biodiversity. 80.7% of the local population live in poverty and critically depend on the maintenance of these ecosystems, which provide them with numerous products (food, energy, construction materials, pharmacopoeia and sources of income) and ecosystem services (water, protection against cyclones, microclimate, soil fertility).

Since 2015, affected communities have been opposing the rare earths mining project on the basis that it will infringe on many of their human rights, including their lands rights and their livelihoods as most of them live mainly from fishing and agriculture, particularly from high value-added export crops such as vanilla, cocoa and coffee that would be destroyed by this mining project.

A number of protest actions have been undertaken by these populations for several years and are still on-going. Affected communities have been continuously calling on state authorities to stop any pilot production attempt by this project as well as to reject its request for an exploitation licence.

The destructive impacts of this mining project on the terrestrial and marine environment, human rights and livelihoods of local communities as well as on the tourism sector, the core sector of the economy of the Nosy Be archipelago, are certain. 

For additional information see: 

Madagascar and the New Frontiers of Sacrifice Zones, Foreign Policy In Focus, April 2023  

China Wrestles with the Toxic Aftermath of Rare Earth Mining - Yale Environment 360, July 2019

The climate footprint of the planned rare earths mining project will be significant, as it will be directly related to the release of greenhouse gases due to forest and vegetation cover clearance in the entire mining concession (estimated at 300 square kilometres), in addition to the indirect emissions by mining operations and the mineral value chain.

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Aerial view of the rare earths project test-site in the Commune of Ankaranobe during its exploration phase..

Photo: CRAAD-OI

This project will have disastrous and irreversible impacts on the Ampasindava Peninsula, a global biodiversity hotspot that was formally designated as a protected area in 2015 over an area of more than 900 square kilometers. 80% of the plants are endemic to Madagascar, and 8% exist only on the peninsula. At least eight species of lemurs live on the peninsula, and six of these are endemic to northwestern Madagascar. Six of these are listed as endangered by the IUCN; the other two are vulnerable. In terms of the marine environment, the Ampasindava Peninsula is located in the Northern Mozambique Channel ecoregion, recognized as the second most diverse coral reef in the world. In 2012, the marine and coastal area around the peninsula was identified as a potential UNESCO World Heritage Site following a scientific assessment of the entire Western Indian Ocean. These habitats are a refuge for many endemic and threatened species, including endangered species of Lemurs.

Local communities claim that the rare earths mining project poses an imminent threat to the communities and the surrounding region. Project critics signal that, although the technology envisaged by Harena Resources Pty Ltd in Madagascar (heap leaching) is described by its Director as "a low impact operation", this process is widely known to be extremely damaging to the environment. In addition to the massive deforestation, together with the destruction of approximately 2,200 hectares of natural vegetation cover and biological resources needed for the livelihoods of local communities, chemicals such as sodium chloride, ammonium sulphate and oxalic acid, as well as a huge quantity of water must be used, leading to considerable toxic and radioactive discharges (including acids and thorium) on the land, groundwater and surrounding populations. 

Communities’ concerns about the risks of mishandling toxic waste are exacerbated by the fact that Harena Resources Pty Ltd as a company has no previous experience in developing rare earths mines and using a surface filtration technology such as heap leaching. This is evidenced in the fact that its Director describes using “a weak ammonium sulfate solution”, which has proved to result in severe environmental degradation and adverse health impacts on workers and nearby communities in China. In June 2011, the Chinese central government enforced a ban on surface mining and tank/heap leaching while implementing in-situ leaching for ion-adsorption rare earths. 

Indeed, the Director of Harena Resources Pty Ltd seems to ignore that to produce 1 ton of rare earths, 7 tons of ammonium sulphate and 1.5 tons of oxalic acid could be needed, as in Bayan Obo (China). According to The Guardian, "the production of one ton of rare earths generates 1,000 tons of water contaminated with ammonium sulfate and heavy metals, and 2,000 tons of toxic waste." Poisoned waters from the heap leaching process of sulfate ammonium clays in Ampasindava could be carried by rivers into the Mozambique Channel, causing marine pollution of the entire area. The torrential rains from the cyclones of Northern Madagascar would threaten to overwhelm sites where toxic sludge is stored in heaps, spreading chemicals into water and land in the entire region. Sulfate pollution of rivers and downstream reservoirs can persist long after mining ceases due to increased microbial production of hydrogen sulfate, a substance that is extremely toxic to many aquatic organisms and plants.

Thus, the destructive risks of this mining project on the terrestrial and marine environment, human rights and livelihoods of local communities as well as on the tourism sector, the core sector of the economy of the Nosy Be archipelago, are very high. 

Rare earths mining is known around the world to be seriously and irreversibly destructive for the environment and people’s health as demonstrated by experiences in China and Mongolia published in several media reports.

As has been well established by the literature on the root causes of the COVID-19 outbreak, the considerable tropical deforestation that would be associated with the planned rare earths mining project would definitely increase the risks of such emerging zoonotic disease with pandemic potential.

A number of protest actions have been undertaken by local communities for several years and are still on-going. It is clear that these affected populations, supported by local, regional and international civil society organisations and in solidarity with people from other regions, will continue actively opposing and challenging the project indefinitely. This is likely to have a critical impact on the performance of this mining project.

Another mining project, operated by a publicly traded Australian company listed on the ASX, in the southwestern region of Madagascar has been suspended since December 2019 due to the lack of consent from affected communities. That project also faced long-term resistance and protest actions. Given this, we believe community opposition is a material risk which has not been disclosed properly by Harena Resources Pty Ltd.

This project poses material risk to Harena Resources Pty Ltd and its prospective shareholders due to the unsustainability of its planned operations combined with enduring and large-scale community resistance that is likely to impact the company’s ability to operationalize the mine and realise the expected financial outcomes.